Complaint filed 8/27/2004, proposing a penalty of $157,500. Complaint alleges: Respondent violated Parts I.A.2, I.C.1, I.C.2, II.B.1, II.B.1, II.B.2 and II.C.1 of the NCDENR Permit by failing to adequately install and maintain temporary or permanent measures to control and retain sediment, including installation and maintenance of silt fencing; failing to install and/or maintain inlet protection; problems with installation and maintenance of sedimentation basins and sediment traps; failure to install diversion ditches; lack of adequate groundcover on lots and basins throughout the site where construction had ceased for more than fifteen (15) days, and for discharges not authorized by the NCDENR Permit